1. When the DNC provisions apply

This procedure is for Quillmarrow’s planned telemarketing campaign to SME owners, using the prospect list in PD-10. It supports the action on G-11: no register-check process was reported and sender details were not standardised.

The Do Not Call (DNC) provisions concern specified messages sent to Singapore telephone numbers. Relevant channels can include voice calls, SMS, messaging apps and fax. The content, recipient, number and channel matter; staff should not assume a message is outside the rules simply because it concerns a business.

Some B2B messages and other situations may be treated differently. Clear and unambiguous consent in evidential form may also be relevant. The Head of Marketing and the DPO should confirm how the rules and any proposed exception apply to each campaign with a Singapore-qualified lawyer. Do not assume that a business relationship, a publicly available number or an old list establishes consent.

Use this procedure with B6 for consent and withdrawal, B3 for the data inventory and B8 for retention. Refer to the PDPC Advisory Guidelines on the Do Not Call Provisions and confirm legal questions with a lawyer.

2. Pre-campaign checklist

The Head of Marketing should complete and document the checklist before any batch is released. A proposed control is not evidence that it has been carried out.

The checklist should be repeated for a later batch if the facts or relevant check status have changed. Do not treat a check for one channel as automatically covering another.

3. Campaign record fields

The Head of Marketing should keep a record for each campaign and batch, with access limited to staff who need it. Include:

• Campaign and batch reference, purpose, proposed message and channels.
• List sources, collection methods and the person or role responsible for each source.
• Number-list or file reference and secure evidence location; avoid copying the full prospect list into the decision record.
• Consent wording and evidence references where consent is relied on, including any gaps or withdrawals.
• DNC check date, relevant registers or channels checked, results, exclusions and evidence location.
• Suppression check, opt-out contact route and any instructions sent to a calling provider.
• Approved sender identification, contact details and message or script version.
• Voice calling-line identity test and outcome, where applicable.
• DPO or legal review, decision, owner, release date and any conditions or unresolved actions.

Keep DNC check records under RS-08 and marketing and consent records under RS-07, subject to Quillmarrow’s confirmed B8 decisions. Do not invent a retention period. Preserve enough evidence to reconstruct the decision without keeping unnecessary copies of personal data.

4. Worked example: Q4 SME owners campaign

This example illustrates one proposed batch; it is not evidence that the campaign was run or that checks occurred.

The Head of Marketing has identified five illustrative list sources for PD-10. Consent evidence is available for three and missing for two of the five:

Consent evidence from the other sources is not, by itself, proof that every intended contact may proceed. The DPO should review the proposed basis, register checks and exceptions with a lawyer where needed.

5. Owner roles and monthly check

The Head of Marketing owns the campaign record, list sources, consent evidence and suppression process. The Sales Manager owns the voice-call script and calling-line test. The DPO reviews questions about applicability, exceptions and unresolved evidence, and coordinates legal advice.

The DPO should conduct a monthly sample check of campaign records, register-check evidence, message versions and opt-out handling. Record findings, corrective actions, owner and target date in B2 under G-11.

By 13 November 2026 (G-11 target in B2), the Head of Marketing should prepare the register-check procedure, standard sender details and campaign record for DPO review. The campaign should not be treated as ready merely because this checklist exists.

6. Go or no-go gate

The campaign starts only when the Head of Marketing can show the DPO all of the following. If any one is missing, the answer is no-go and the gap stays open in B2 under G-11.

7. Next actions

This checklist is practical support, not legal advice.